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Tax Disputes-Litigation

Tax Audits and Reassessments

  • Representing clients during tax audits conducted by the Canada Revenue Agency (CRA) and other tax authorities.

  • Assisting clients in responding to reassessment notices and negotiating settlements.

2

Tax Appeals

  • Preparing and filing notices of objection to challenge tax reassessments.

  • Representing clients in appeals before the Tax Court of Canada, the Federal Court, and the Federal Court of Appeal.

3

Corporate and Personal Tax Disputes

  • Handling disputes related to corporate income tax and personal income tax assessments.

  • Addressing issues such as deductions, exemptions, tax credits, and income characterization for both individuals and businesses.

4

International Tax Disputes

  • Representing clients in cross-border tax disputes involving transfer pricing, foreign tax credits, and tax treaties.

  • Assisting multinational corporations and individuals with issues related to international tax compliance and planning.

5

GST/HST Disputes

  • Representing clients in disputes involving the Goods and Services Tax (GST), and Harmonized Sales Tax (HST).

  • Addressing issues related to input tax credits, tax collection, and remittance obligations.

6

General Anti-Avoidance Rule (GAAR)

  • Defending clients in cases involving allegations of tax avoidance and the application of the General Anti-Avoidance Rule (GAAR).

  • Providing strategic advice on complex tax planning structures and defending their validity against CRA challenges.

7

Corporate Expenses and Small Business Deduction Disputes

  • Handling disputes related to the deductibility of corporate expenses and eligibility for the small business deduction.

  • Assisting small businesses in navigating complex tax rules and defending their claims against CRA assessments.

8

Trusts and Estates Tax Disputes

  • Managing disputes related to the taxation of estates and trusts, including issues of valuation, income distribution, and capital gains.

  • Representing executors, trustees, and beneficiaries in tax-related litigation and compliance matters.

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